Schoolcraft v. The City Of New York et al

Filing 526

DECLARATION of Brian E. Lee in Support re: 525 SECOND MOTION in Limine to preclude any testimony regarding DJ action.. Document filed by Isak Isakov. (Attachments: # 1 Exhibit Exhibit A: May 2015 Order, # 2 Exhibit Exhibit B: January 2015 Order, # 3 Errata Exhibit C: Third Amended Complaint)(Lee, Brian)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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ADRIAN SCHOOLCRAFT,

10CV6005(RSW)

Plaintiff,
-against-

DECLARATION OF
BRIAN E. LEE

THE CITY OF NEW YORK, DEPUTY CHIEF MICHAEL
MARINO, Tax Id. 873220, Individually and in his Official
Capacity, ASSISTANT CHIEF PATROL BOROUGH
BROOKLYN NORTH GERALD NELSON, Tax Id. 912370,
Individually and in his Official Capacity, DEPUTY
INSPECTOR STEVEN MAURIELLO, Tax Id. 895117,
Individually and in his Official Capacity, CAPTAIN
THEODORE LAUTERBORN, Tax Id. 897840, Individually and
in his Official Capacity, LIEUTENANT JOSEPH GOFF, Tax Id.
894025, Individually and in his Official Capacity, SGT
FREDERICK SAWYER, Shield No. 2576, Individually and in
his Official Capacity, SERGEANT KURT DUNCAN, Shield No.
2483, Individually and in his Official Capacity, LIEUTENANT
CHRISTOPHER BROSCHART, Tax Id. 915354, Individually
and in his Official Capacity, LIEUTENANT TIMOTHY
CAUGHEY, Tax Id. 885374, Individually and in his Official
Capacity, SERGEANT SHANTEL JAMES, Shield No. 3004, and
P.O.’s “JOHN DOE” #1-50, Individually and in their Official
Capacity (the name John Doe being fictitious, as the true names
are presently unknown) (collectively referred to as “NYPD
defendants”), JAMAICA HOSPITAL MEDICAL CENTER, DR.
ISAK ISAKOV, Individually and in his Official Capacity, DR.
LILIAN ALDANA-BERNIER, Individually and in her Official
Capacity and JAMAICA HOSPITAL MEDICAL CENTER
EMPLOYEE’S “JOHN DOE # 1-50, Individually and in their
Official Capacity (the name John Doe being fictitious, as the
true names are presently unknown),
Defendants.
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BRIAN E. LEE, declares the following pursuant to 28 USC §1746, under penalty of
perjury:

That I am a Member of Ivone, Devine & Jensen, LLP, the attorneys for the defendant
ISAK ISAKOV, M.D., and am fully familiar with the facts and circumstances of this action
by virtue of a review of the file in my office.
That this Declaration is submitted in support of the instant motion in limine of the
defendant ISAK ISAKOV, M.D.
Attached hereto are the following Exhibits:
Exhibit A:

The Order of Judge Sweet dated May 6, 2015

Exhibit B:

The Order of Judge Sweet dated January 2015

Exhibit C:

The plaintiff’s third amended complaint

WHEREFORE, defendant ISAK ISAKOV, M.D. respectfully requests that the motion
in limine be granted in its entirety.
Dated:

Lake Success, New York
September 22, 2015
Yours, etc.,
IVONE, DEVINE & JENSEN, LLP
/s/ Brian E. Lee
By:
BRIAN E. LEE (9495)
Attorneys for Defendant
ISAK ISAKOV, M.D.
2001 Marcus Avenue, Suite N100
Lake Success, New York 11042
[phone]

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